#3 Comments on Draft Strategic Plan on Accessible Transportation

We have 28 comments to the Draft Strategic Plan on Accessible Transportation and, now that the deadline has passed, I am grouping the rest into categories. In this post are two summaries of comments submitted by cities, in fact, the only cities to share their responses to the draft plan. People with disabilities live in every city, every county and every state. Yet the two comments submitted represent a mere two municipalities of any kind. According to the Census Bureau, there are just over 89,000 municipalities in the US.

Engagement ≠ Opportunity, Engagement = > Opportunity

I would guess that accessibility is important to every city and town. Indeed I am certain that many city mayors and staff would agree. But I wonder that many lack the staff to monitor Federal Register notices, which is a nice public engagement tool if you are from the 19th century rather than the 21st century. To be fair, the Federal Register does allow one to monitor notices with keywords of one's choice, which prompts an email to be sent every time those keywords appear in any kind of notice. 

So maybe it isn't the opportunity itself that is hidden, but the Federal Register doesn't actively reach out to stakeholders on any particular topic. That falls to whomever wishes to do so, mainly non-profit advocacy groups that are themselves stretched thin. Advice to those advocacy groups representing people with disabilities: Do better outreach for comment submitting campaigns. I will be having a post on that topic at some point. 

I am guessing that any city responding to the draft plan is going to come out in favor of expanding accessibility because it would be like opposing apple pie to say otherwise, at least publicly. This guess turns out to be correct, but these cities that have submitted comments are offering concrete guidance about routes to that end.

Comment from Portland Bureau of Transportation

This comment is from PBOT, the Bureau of Transportation in Portland, OR. Portland suggests engaging municipalities more to expand accessibility through city accessibility plans. "State ADA Transition Plans focus on state highways, which in many cases, run through cities and operate as city streets, but only as a small part of a city’s transportation system. A much bigger impact to accessibility can be accomplished by implementation of city ADA Transition Plans."

In case you are unaware, different streets have different designations. In my state of Maryland, any main thoroughfare is a state road, with some county roads, and then local roads. This really messes with local control and becomes even worse in those states where state legislatures and governors are very anti-city, notably Texas. The letter explains, "City transition plans focus entirely on transportation system elements: streets, sidewalks, pedestrian signals, transit stops, accessible parking, and curb ramps that are used by pedestrians every day. Implementing these plans will get people to school, work, medical appointments, the market, and provide opportunities for healthy activities like biking, running, and walking." 

Quite rightly, PBOT points out that despite the 30-year-old Americans with Disabilities Act (ADA), there is much to be done to fulfill its mandate. PBOT suggests an economic stimulus that includes implementation of local accessibility plans, with opportunities given to historically underrepresented contractors (such as minority-owned businesses).

In terms of guidance, PBOT asks for advice concerning service animals on public transit and on shared on-demand transportation, such as taxis. 

Comment from City of San Diego, California

I am going to be a bit critical here, not of the comment itself, but of affixing the equivalent of a bunch of sticky notes to the source document. Yes, this "comment" is actually notes thrown on the margins of the draft plan. Harumph. 😠

The comment requests funding increases or creation of funding to increase geographic equity beyond rural areas by expanding accessibility in underserved neighborhoods; and funding to support complaint processing to enforce the ADA, thus decreasing backlogs and processing time.

San Diego suggests national standards and technical assistance for several aspects of broadening accessibility, specifically requesting: 

• Design guidelines for the right of way
• Development of national standards of accessibility and training
• Adoption of public rights-of-way accessibility guidelines (PROWAG)
• Outreach and education about ADA enforcement for people with disabilities

Sidewalks are another area of concern. San Diego is argues in favor of adding sidewalk maintenance to the list of barriers to accessibility and including sidewalk design to the necessary steps to accessibility.

On another note

Thinking of topics of history that can guide us - positively or negatively - toward a better transportation future. Pondering a podcast about these. Feel free to send a note via LinkedIn, email or twitter - @DriverlessRev or at grossglaser@gmail.com. Whatever.

• Roman roads/early American roads
• Union Stations
• History of Braille 
• Rebuilding of DC Union Station
• Polio and the ADA
• Disappearance of streetcars 
• History of the American suburb and racism
• Transportation in the Constitution
• Why Isn't there a DC subway station in Georgetown?
• Thriving Buses in the Midwest
• Rural versus Urban in Colonial and Early America 
• History of planning and why we elevate public meetings